Comment submitted by Main Street Foundation - Center for Regulatory Analysis and Engagement (CRAE)

Summary: The Center for Regulatory Analysis and Engagement (CRAE), a project of the Main Street Foundation, supports the EPA's proposed revisions to the New Source Review (NSR) permitting regulations. They argue that distinguishing between pollutant-emitting activities and non-emitting site preparation improves regulatory certainty, reduces administrative burdens, and aligns the program more closely with the Clean Air Act's environmental objectives.